I have a restaurant client I've determined qualifies for the ERC based on a partial shutdown. I am dealing with PPP and other caveats, but I'm trying to determine the amount of qualifying wages for the 75 employees of the company.
They handle their own payroll and pay wages monthly.
In this case (for example), Idaho gave a stay at home order on March 25th (no indoor dining), which remained in place beyond March 31.
Are qualified ERC wages determined based on the pay date or are they accrued based on the dates the wages were earned??
All but 1 of the employees in this case received their check for March work (1st through 31st) on April 3rd. Obviously that would be Q2 salary. If April 3rd falls in the shutdown period (it does) do 100% of those wages qualify? Or do we need to prorate the wages (x 7 shutdown of 31 total days)? Or do we need to determine actual hours worked from March 25th to 31st?
That one employee is a different example but for Q1. She was paid on March 27 for the period ending March 25th. Does 1/25th of her pay qualify for Q1 ERC? or does her entire wage qualify? Or do we need to figure out how much she worked on March 25th and that would be her qualifying wage?